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IN THE COURT OF THE SENIOR CIVIL JUDGE: KANDUKUR

H.M.O.P. NO. /2023

Udayagiri Praveen Kumar ...... Petitioner
Vs
Udayagiri Lavanya ...... Respondent
PETITION FILED ON BEHALF OF THE PETITIONER U/S 13(1) (1-b) OF HINDU
MARRIAGE ACT.

1. Description of the Petitioner: - The petitioner is the son of Mala Kandiah Hindu,
aged about 27 years, Business, R/o. Rallapadu Village, Gudluru Mandal, SPSR Nellore
District. His address for service of notice etc is that of his counsel Sri. K. V. Aravind
Naidu, Advocate, Kandukur, Cell No. 9440219624

2.Description of the Respondent: - The respondent is the wife of Praveen Kumar,

D/o.Talathoti Danaiah, Hindu, aged about 22 years, house wife, presently residing at
her parental house at R/o. Rallapadu Village, Gudluru Mandal, SPSR Nellore District. Her
address for service of notices etc., is the same as stated above.

3. The petitioner humbly submits that the petitioner married the respondent on
06.06.2021 at petitioner’s house at Rallapadu Village, Gudluru Mandal, SPSR Nellore
District as per the Hindu rites, caste and usage. Soon after the marriage the respondent
joined with the petitioner at petitioner’s house and their marriage is duly solemnized
and consummated. The petitioner and respondent lived happily at about six months
only. During their wedlock they have no issues.

4. The petitioner submits that from the beginning of the marriage the respondent used
to dislike the petitioner and did not share bed with the petitioner. The respondent used
to say on the face of the petitioner that she has no love and affection towards the
petitioner. The respondent did not attend domestic works also. The respondent
developed illicit contacts with unknown person. Whenever the petitioner questioned
about the respondent behaviour the respondent behaving with the petitioner very
adamantly and abusing him in filthy language to pacify her illicit contact. The petitioner
bares the attitude and behaviour of the respondent that she may change her attitude
and behaviour for her family relation. But the respondent never changes her attitude
and behaviour. All the efforts of the petitioner are futile. Moreover, the respondent
bluntly says on the face of the petitioner that she has no love and affection towards the
petitioner. But the respondent clearly says to the petitioner she has love and affection
with that man not with the petitioner. The petitioner vexed to live with respondent due
to her attitude and behaviour. The respondent harassed the petitioner with mentally
and physically and also the respondent did not seeing welfare of the petitioner’s parents
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not cooking food and the petitioner’s parents are old aged persons. The respondent
also threatening the petitioner with dire consequences and also threatening the
petitioner that she is going to file false criminal cases against the petitioner and his
family members.

5. In the month of 10.03. 2023 the respondent left the house of the petitioner with gold
ornaments and sarees purchased by the petitioner and huge cash without any
intimation or knowledge to the petitioner. The petitioner made several attempts
personally to take back the respondent to his marital fold. The respondent bluntly
refused to live with the petitioner. Moreover, the respondent said on the fact of the
petitioner, she has no love and affection towards the petitioner. Thereafter the
petitioner sends the mediators by names Daggumati Malakondaih, Yerrejonna
Malakondaiagh along with petitioner parents four times to the respondent’s house and
requested the respondent come and join with the petitioner and lead happy marital life.
But the respondent bluntly refused to do so and moreover the respondent said to the
mediators that she has no love and affection towards the petitioner and she also said
that she cannot live with the petitioner. All the efforts of the petitioner are futile. Since
the month of 20.01. 2023, the respondent voluntarily deserted the petitioner. The
petitioner has lost his hopes that the respondent will not come back to the petitioner’s
house to lead her happy marital life as her will and wish.

6. The petitioner has no other option to get divorce from the respondent on the ground
of cruelty.

7. There is no collusion between the petitioner and the respondent in filing this petition
and no such similar petition filed by any one in any other court for the same relief.
Hence this suit.

8.The Cause:- The action for the petition arose when the marriage between the
petitioner and respondent took place on 06.06.2021 at Petitioner’s house at Rallapadu
Village , Gudluru Mandal, SPSR Nellore District as per Hindu caste, custom and usage,
soon after the marriage, the respondent joined with the petitioner at petitioner’s house
and their marriage is duly solemnized and consummated; when the petitioner and
respondent lived happily at about one year only; when the respondent left the house of
the petitioner with gold ornaments and sarees purchased by the petitioner and huge
cash without any intimation or knowledge to the petitioner; when the respondent
voluntarily deserted the petitioner; when the marriage took place at Rallapadu Village,
Gudluru Mandal Prakasam District and the petitioner is residing at Rallapadu Village,
Gudluru Mandal, Prakasam District Within the jurisdiction of this Hon’ble Court. Hence
this Hon’ble Court has got jurisdiction to entertain this petition.
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9. A fixed court fee of Rs. 10 /- is paid herewith under article 1(VII) of schedule II of
A.P. Court fee and suits valuation Act.
10. Therefore the petitioner prays that the Hon’ble Court may be pleased to pass
judgment and decree in his favour.
a) By dissolving the marriage in between the petitioner and the
respondent.
b) For costs, and
c) For such other reliefs as the Hon’ble Court deems fit and
proper in the interest of justice.

Petitioner

I, the petitioner herein does hereby declare that the above stated facts are true
and correct to the best of my knowledge. Information and believed.

Advocate for petitioner Petitioner

List of Documents:

1. The wedding invitation card.

2. The Marriage photos along with CD of the petitioner and respondent.
3. Xerox Aadhar Card of the petitioner

Date: .08.2022

Place; Kandukur Advocate for petitioner

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IN THE COURT OF THE SENIOR CIVIL JUDGE: KANDUKUR

H.M.O.P. NO. /2023

Udayagiri Praveen Kumar .……...... Petitioner

Vs
Udayagiri Lavanya ….......... Respondent

PROOF AFFIDAVIT

I, Udayagiri Praveen Kumar, son of Mala Kondaiah Hindu, aged about 27 years,
Business, R/o. Rallapadu Village, Gudluru Mandal, SPSR Nellore District, do hereby
solemnly affirm and state as follows:

1. I am the petitioner herein and I know the facts of the case.

2. I humbly submits that I married the respondent on 06.06.2021 at my house at

Rallapadu Village, Gudluru Mandal, SPSR Nellore District as per the Hindu rites, caste
and usage. Soon after the marriage the respondent joined with me at my house and
our marriage is duly solemnized and consummated. Myself and respondent lived happily
at about one year only. During our wedlock they have no issues.

3. I humbly submit that from the beginning of the marriage the respondent used to
dislike me and did not share bed with me. The respondent used to say on my face that
she has no love and affection towards me. The respondent did not attend domestic
works also. The respondent developed illicit contacts with unknown person. Whenever I
questioned about the respondent behaviour the respondent behaving with me very
adamantly and abusing him in filthy language to pacify her illicit contact. I bare the
attitude and behaviour of the respondent that she may change her attitude and
behaviour for her family relation. But the respondent never changes her attitude and
behaviour. All my efforts are futile. Moreover, the respondent bluntly says on my face
that she has no love and affection towards me. But the respond dent clearly says to me
she

has love and affection with that man not with me. I vexed to live with respondent due
to her attitude and behaviour. The respondent harassed me with mentally and
physically and also the respondent did not seeing welfare of the petitioner’s parents not
cooking food and the petitioner’s parents are old aged persons. The respondent also
threatening me with dire consequences and also threatening me that she is going to file
false criminal cases against me and my family members.
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4. I further submit that in the month of 10.03. 2023 the respondent left my house with
gold ornaments and sarees purchased by me and huge cash without any intimation or
knowledge to me. I made several attempts personally to take back the respondent to
his marital fold. The respondent bluntly refused to live with me. Moreover, the
respondent said on my face, she has no love and affection towards me. Thereafter I
send the mediators by name Daggumati Malakondaih, Yerrejonna Malakondaiagh along
with petitioner parents four times. The respondent’s house and requested the
respondent come and join with me and lead happy marital life. But the respondent
bluntly refused to do so and moreover the respondent said to the mediators that she
has no love and affection towards me and she also said that she cannot live with me.
All the efforts of me are futile. Since the month of 20.01. 2023 the respondent
voluntarily deserted me. I have lost his hopes that the respondent will not come back to
my house to lead her happy marital life as her will and wish.

Hence, I prayed the Hon’ble Court may be pleased to pass orders as prayed for by
me in the annexed petition in the interest of Justice.

Deponent

Solemnly affirmed and executed before me on -08-2023 at Kandukur

Advocate for petitioner Advocate

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IN THE COURT OF THE SENIOR CIVIL JUDGE : KANDUKUR

H.M.O.P. NO. /2023

Udayagiri Praveen Kumar .... Petitioner

Vs
Udayagiri Lavanya ..... Respondent

Address Particulars of the Petitioner:

Udayagiri Praveen Kumar,

son of Mala Kondaiah Hindu,
aged about 27 years, Business,
R/o. Rallapadu Village,
Gudluru Mandal,
SPSR Nellore District

Address Particulars of the Respondent: -

Udayagiri Lavanya
Wife of Praveen Kumar,
D/o.Talathoti Danaiah, Hindu,
aged about 22 years, House wife,
Presently residing at her parental house at
R/o. Rallapadu Village,
Gudluru Mandal,
SPSR Nellore District

Advocate for Petitioner

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SRI. K.V.A.N

IN THE COURT OF THE SENIOR CIVIL

JUDGE: KANDUKUR.

H.M.O.P. NO. /2023

Udayagiri Praveen Kumar

.... Petitioner
Vs
Udayagiri Lavanya
..... Respondent

PETITION FILED ON BEHALF OF THE

PETITIONER U/S 13(1) (1-B) OF HINDU
MARRIAGE ACT

Filed on : .08.2023

Address for Service: -

Sri. K.V. Aravin Naidu

Advocate
Kandukur
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